Assistant Vice President - Regulatory Compliance
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Role Purpose
The Assistant Vice President Compliance Advisory is a risk management role that has a remit and responsibilities for implementation and management with guidance from the Head of Compliance Advisory, of all aspects of Regulatory Compliance (RC) and Financial Crime Compliance (FCC), including impact analysis of regulatory changes, and coordination and execution of the various RC and FCC work streams and assurance in India, while ensuring alignment with Global Standards.
The role requires strong partnership with the entity’s business and leadership team, interfaces with both Risk and General Compliance and has responsibility for driving the implementation of policy arising out of Global Standards Committee. It will monitor and track the progress of various work streams and initiatives underway which fall under the umbrella of RC and FCC Risk and Global Standards, provide policy advice related to products, services and clients, and ensure that the RC and FCC function is resourced adequately to address the risks associated with the business in India.
The role assumes responsibility for the implementation and dissemination of the applicable laws and regulations, e.g. The Prevention of Money Laundering Act, 2002 (PMLA 2002) and applicable regulatory guidelines on FCC.
The role will also need to be aware of the regulatory changes to ensure communication within the HSCI and develop appropriate policy and framework to manage the changes in HSCI.
The role requires strong partnership with business to drive and accelerate the execution of RC and FCC programmes that directly impact business performance.This role is responsible for the implementation of RC and FCC policies in to the business and as such it will require close collaboration with various Risk and business functions in the entity.
Key activities and decision making areas
Impact on the Business
·Identification of RC and FCC risk change and potential impacts on the business model in the entity.
·Continuous review for appropriateness of framework to monitor RC and FCC developments impacting on the businesses in the entity.
·Assist in implementation of programmes to quantify impacts and implement actions to address, manage and mitigate impacts of regulatory changes on the entity.
·Assist in implementation, as required, market product suitability, sales and staff remuneration policies and systems that ensure that the business’s exposure to RC, FCC and reputational risks are managed, in a practical and effective manner, including efficient and reasonable deployment of resources and an understanding of the business operations and needs.
·Assists line management in establishing and implementing global standards and strategic policies which ensure business’s exposure to current risks and emerging arising risk is managed appropriately, in a commercially focused and practical manner.
·Works closely with Financial Intelligence Unit and Business Financial Intelligence Units to manage Risk and Compliance matters in India.
·Reviews and assists in the effective deployment of the RC and FCC Assurance function.
·Regular monitoring of specific compliance issues pertaining to individual and non-individual client accounts, staff dealing.
Customers/Stakeholders
·To protect the company’s interests by ensuring that product / process / systems in use are compliant with regulations and internal guidelines.
·Assists in liaison with relevant stakeholder within the business and functional teams to provide expertise and support on all RC and FCC related matters.
·Interaction with Regulators and industry bodies in India on RC and FCC matters relating to the entity.
·Assists in ensuring appropriate timely and relevant risk information is provided to the line management.
Leadership and Teamwork
·Self-development and team work.
·Share best practice with group offices, other business lines and other entities.
·Maintain and develop positive and professional working relationships with senior business managers at the Global and Country levels.
Operational Effectiveness and Control
- Focus on implementing the aligning the business operating practices with changes in Global Regulatory Compliance Standards
- Ensure all GSM, DIM, FIMs, BIMs and dispensations, etc. are updated for changes in Regulation and impacts on business.
- Resolve any/all identified issues promptly, and escalate concerns to management as appropriate to ensure timely awareness of any material concerns.
- Maintain and observe all HSBC control standards and implement and observe the Group Compliance Policy, including the timely implementation of recommendations made by internal/external auditors and external regulators.
- Maintain awareness of operational risk within assigned portfolio and minimise the likelihood of it occurring including its identification, assessment, mitigation and control, loss identification and reporting.
Major Challenges
HSCI is an extremely diverse business and is facing an increasingly regulated and complex global environment with often little consistency between laws and regulations in different jurisdictions and regulators taking a far more aggressive approach in ensuring local compliance with their requirements and imposing increasingly stringent sanctions for breaches.
It is the role of the Assistant Vice President Compliance Advisory to assist the Head of Compliance Advisory and senior management within the HSCI in achieving a balance between the demands of regulators, external bodies and governmental initiatives, HSCI business and ultimately the Group’s shareholders and customers; being aware of the political, management, regulatory and reputational implications of a particular decision and courses of action.
In order to effectively manage change in a volatile environment, the jobholder is required to have a broad and deep understanding of businesses, regulatory and industry issues, as well as the competitive landscape. The incumbent will be required to stay abreast of the rapidly changing regulatory environment as it relates to RC and FCC and the more stringent regulatory interface and intervention across multiple jurisdictions, which is complicated further given the dynamic nature and differing pace of change.
The incumbent is required to ensure the consistent application of the highest Risk management standards notwithstanding the complexities of products and business operations in India. Risk is forward looking. The incumbent would identify, plan and implement change programmes to ensure that the HSCI remains in line with regulatory requirements. A balance must be maintained between the local, regional and global priorities. The incumbent would need to balance between sometimes conflicting needs and priorities of different teams within Risk departments and across countries.
This role also needs to lead without authority and able to collaborate with multi stakeholders and deliver results. The role holder must be able to influence senior management and articulate clear business reasons for change initiatives.
Role Context
This role will report to the Head of Compliance Advisory.
India is an emerging economy and a strategic priority for the Group. It is a developing regulatory jurisdiction, which is regulated by multiple regulators. While the regulations are voluminous and complex; sometimes prescriptive; sometimes ambiguous and sometimes archaic, the operating environment on the other hand is dynamic, demanding and diverse with multiple stakeholders.
The NSE, BSE and SEBI primarily regulate the HSCI’sbusiness in India. Its regulations are complex requiring interpretation and subject to frequent amendments and clarification. The regulators are increasingly delegating the monitoring of its policies and regulations to the financial institutions and accordingly the observance of directives/guidelines is now generally the responsibility of financial instituions which increases the inherent risks.
Regulators are increasingly becoming sensitive to retail customer needs and grievances. The economic and business environment contributes to the growing compliance risk profile of the HSCI’sbusinesses. Competition from peer institutions have increased and their increasing footprint puts pressure on business. Knowledge of products and importantly, practices of competition is an absolute necessity.
HSCI is people intensive business and requires continuous Compliance focus with regard to compliance to financial crime. The Assistant Vice President Complaince Advisory would be responsible to have an oversight on all activities pertaining to RC and FCC in HSCI to mitigate the risks.